High Net Worth Foreign National - Agent Support...

High Net Worth Foreign NationalProgram and Guidelines Updated 02/01/2016

For U.S. producers only, for use only in the United States. Not for public use or distribution.


Overview

Getting approved for High Net Worth Foreign National (HNWFN) • Sales Producer Eligibility Guidelines

• HNWFN Distributor Questionnaire

• Voya® Business Guidelines

Selling to HNWFN Individuals • Solicitation Guidelines

• Ownership and Administration

• Referral Guidelines

Keeping Compliant • Agent Appointment Process

• Agent Monitoring Program

• Training & Sales Program

• Audit Program

• Premium Payments

Policy Administration • Policy Activation

• In-force Policy Administration

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1For U.S. producers only, for use only in the United States. Not for public use or distribution.

The transfer of wealth from generation to generation within a family is an important part of financial planning - regardless of where you live. Life insurance benefits can be an integral part of that process. There are wealthy individuals around the world who spend time in the United States, or have significant assets here. They may be eligible to obtain life insurance coverage from Voya Life Companies1 as part of their estate planning.

It’s a complex market, and this guide will help you determine whether an interested prospect may qualify to participate in Voya’s High Net Worth Foreign National Program. As companion pieces, also see #169507 for the Voya Life Companies’ HNWFN Underwriting Overview and #177122 Underwriting Requirements Guide - HNWFN.

If you have any questions regarding these guidelines, please contact your local sales team or underwriter.

Source: The Wealth Report 2014

The tax consequences of an international financial plan including the income, estate and gift tax consequences of purchasing and owning life insurance must be determined by the client’s tax advisers.

Voya’s International Underwriting Guidelines define a “Foreign National” as a “citizen of other than U.S. or Canada, not meeting Voya’s U.S. permanent resident qualifications.”1Voya Life companies refers to Security Life of Denver Insurance Company, ReliaStar Life Insurance Company and ReliaStar Life Insurance Company of New York.

The number of high net worth individuals across the world has ballooned by 59% since 2003, more than doubling in the Middle East, Latin America, Australia, Asia and Africa. The number of centa-millionaires - those with US $100m in net assets - has risen by 62%, while the tally of billionaires has climbed by 80% to 1,682, according to Wealth Insight, a leading wealth intelligence firm.

The number of billionaires in Asia is also forecast to over take the number in Europe over the next decade. In 10 years' time there will be more billionaires in India than in the UK.

The growth of high net worth individuals in China and India, coupled with an eye-catching 144% increase in Indonesia and a stellar 166% hike in Vietnam, will help push the total number of wealthy individuals in Asia up by 43%.

Over the next decade, the growth in high net worth individuals will be highest in the Middle East, Latin America and Asia, with the biggest rise of all in Africa, albeit from a low base.

Opportunity Abounds!

2 For U.S. producers only, for use only in the United States. Not for public use or distribution.

Producer Eligibility and GuidelinesBecause of the solicitation requirements applicable to HNWFN cases, we require every producer seeking to participate in Voya’s HNWFN Program to certify their understanding of our solicitation guidelines. These cases require detailed distributor understanding of referral and solicitation rules and we reserve the right to determine which producers are able to participate in the program.

Getting approved for HNWFN sales


HNWFN Distributor Qualification QuestionnaireThe first step for an interested distributor is to complete an Application for Appointment and Agreement, if not already contracted with Voya Life Companies, and complete a HNWFN Distributor Qualification (#147790) for Voya executive approval. A few things to keep in mind as you complete the form:

Every individual who will be involved in the sales process must complete a separate questionnaire.

Signing the certification:

• If you are an employee of an entity such as a corporation or limited liability company, then an officer of that entity (with legal authority) must also sign the questionnaire as certification.

• If you are submitting a questionnaire on behalf of a contracted agency (corporation or other entity), the form must be signed by a corporate officer.

• If you are signing insurance applications in the name of an agency, each entity needs to complete a questionnaire.

Information is requested regarding the target market, including an estimate of written annualized premium by jurisdiction and product type.

Voya also needs to confirm that the producer will comply with our rules for soliciting sales to foreign nationals.

We expect that all parties identified as potential participants in the program will review and agree to abide by Voya’s Rules for Soliciting Sales to Foreign Nationals (listed on the form).

Certification

The remainder of the questionnaire requires certain certifications related to the program and a listing of Voya’s Rules for Soliciting Sales to Foreign Nationals.

By signing the questionnaire, you are certifying that you understand the principles of Voya’s HNWFN Program and agree to comply with our requirements.

Voya Business GuidelinesIn addition to the guidelines specific to the HNWFN Program, all producers are also expected to comply with Voya Life Companies’ Business Guidelines as outlined on the Qualification Questionnaire. For additional information please see the “Compliance” section on the Voya for Professionals site (voyaprofessionals.com).


Selling to HNWFN IndividualsSolicitation Guidelines • Solicitation and communication includes, but is

not limited to, delivery of contracts, marketing materials or letters soliciting the purchase of insurance, meeting with clients to discuss life insurance or other similar prospecting type activity.

• When outside the U.S., a referral source may only discuss the role of life insurance in meeting a client’s financial objectives.

• Prospects outside of the United States should be referred to the producer through an appropriate referral and should contact the producer at the recommendation of an advisor. In most cases, it is expected that the advisor will be a professional such as an attorney or accountant or a private banker. Such individuals may make a referral to a producer in the United States in recognition that a life insurance policy issued in the United States may help a client in meeting their personal, business, retirement or wealth transfer objectives.

• A producer shall not conduct any prospect meetings, presentations, completion of applications and related forms, medical exams, field underwriting (including without limitation, evaluation of any change in insurability between the time of application and issuance of a policy) or policy delivery outside the United States.

• A prospective insured must travel to the United States to be solicited for the sale and sign the application while physically present in the United States. The application should be signed by the insured in the state where the policy will be issued and delivered. Voya Life Companies will record documentation confirming the insured’s presence in the United States.

• A producer must deliver the policy to the policy owner in person in the state where the policy is issued. If the policy owner is the HNWFN insured, travel documentation reflecting the owner’s presence in the U.S. for delivery should be collected and retained. Use of a Limited Power of Attorney for delivery may be available where the owner is the HNWFN insured.

It is the responsibility of every producer to avoid any activity that might be viewed as insurance activity under local laws concerning permissible activities in a client’s country or jurisdiction of residence. Local laws relating to a resident’s purchase of insurance products may be very restrictive, and may even apply beyond local borders. Consequently, producers should not engage in any in-country activity directly or indirectly. The prospect should be advised to consult an attorney for country specific advice regarding the purchase of insurance outside their country or jurisdiction of residence.

You also need to be aware of how you approach prospects. Keep these rules in mind:

• No specific insurance products may be discussed with a prospect while the prospect is in their country or jurisdiction of residence. All solicitation (including marketing materials) concerning the sale of life insurance products, including all telephone, fax or other electronic or delivered correspondence, must take place in the United States.

• No written materials of any kind, in any way referring to Voya Life Insurance Companies’ products, may be sent or delivered outside of the United States.

• Voya Life Insurance Companies’ products must not be promoted through the use of cold calls, mailings, seminars, advertisements, or any other activities designed to create public interest in the product outside of the United States.

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Ownership and Administration HNWFN residents of many countries may directly own a policy insuring themselves. However, in some cases we will require that the owner/applicant of a policy be a United States individual or entity. In many cases, these clients will set up a United States trust to be the owner of a policy. Please consult underwriting for guidelines and availability of ownership arrangements.

All premium payments must be paid in United States dollars through a United States bank.

At no time can any producer arrange for translation or personally translate any contracts, marketing materials, applications, forms or illustrations into a foreign language. Any required translations will be completed by Voya Life Companies. Voya Life Companies may provide an approved translated disclosure document in certain languages that will inform all insureds and policy owners that all communications will be in English.

The policy must be administered in the United States through an address in the United States. All policy holder communications such as premium bills, annual statements and lapse notices will be sent to this address. The policy owner may not use the address of the agent, agency or anyone associated with the sale or solicitation of the policy.

Referral GuidelinesMany producers participating in Voya’s HNWFN Program rely on referrals from financial professionals. Please note that:

No referral may be obtained from an individual or entity that is licensed as an insurance agent in the insured’s country or jurisdiction of residence. As a result, all business submitted to Voya Life Companies must be referred by an individual or entity that is not a licensed insurance agent in or from the country of residence of the prospective insured or applicant/owner.

Consequently, the following activities are prohibited:

ā Conducting seminars or distribution announcements, mailings, unsolicited emails, or sending faxes that seek to attract local sales representatives in foreign jurisdictions.

ā Communication directly and in person with prospective purchasers in the United States by individuals not appointed with Voya Life Companies.

ā Conducting business with a third party marketing organization in a foreign jurisdiction such as a brokerage organization that in turn has an appointment, or seeks to appoint, individuals to sell the product.

ā Payment of any kind, to any person in the country or jurisdiction of residence of the insured, for referring such individual to the producer for the purchase of insurance products is strictly prohibited. That means a producer that is appointed with Voya Life Companies may not pay compensation by, or on behalf of, Voya Life Companies and its affiliates, to a person or entity in the insured’s country or jurisdiction of residence for the purchase of life insurance products issued by Voya Life Companies. Commissions may not be shared with anyone not contracted and appointed with Voya Life Companies.



Agent Appointment Process In addition to requirements already in place for life insurance agent appointments (including regulatory, personal and financial background checks) every interested HNWFN producer must complete the above-mentioned HNWFN Distributor Questionnaire (#147790).

Compliance will review the producer’s complaint and investigation history. Any concerns regarding agent conduct will prevent the producer from participating in this program.

Agent Monitoring Program Producers accessing the HNWFN program are expected to follow the Business Guidelines and Solicitation Guidelines outlined within this document, and sales activity will be monitored for compliance.

Issues with solicitation practices or other agent misconduct will result in termination of the agent’s ability to participate in the HNWFN Program and/or other action under the agent’s agreement with Voya Life Companies.

Training & Sales Program In further support of the HNWFN Program and in conjunction with sales, Voya will conduct periodic training. During the training, we will review the Program Guidelines and take time to explain the specific requirements therein. It is Voya's intent to solicit feedback from our distribution partners on the Program Guidelines to promote their implementation and ease of use.

Audit ProgramIn an effort to ensure compliance with Voya HNWFN guidelines, Voya implemented an audit program. The audit program is carried out by Voya's Corporate Audit Services (CAS). It will be carried out consistently with Voya's audit methodologies using generally accepted auditing standards.

On a risk adjusted periodic basis, CAS will conduct an audit of a limited number of HNWFN sales though a random risk-weighted sampling process. Inherent in this process will be the development of an inventory or risks associated with the HNWFN business leading to a thoughtful approach to risk analysis. The audit will review critical components of the program guidelines including review of questionnaires, applications, solicitation, policy delivery requirements, policy administration and compliance.

Premium PaymentsAll premium payments must be paid in U.S. currency and through a financial institution governed by U.S. law (ex. U.S. bank or U.S. branch of a foreign owned bank). In addition, the normal monitoring of any suspicious activity on these policies will be handled by Voya Compliance.

All aspects of the insurance transaction must be completed in the U.S. - including solicitation, completion of the application, medical examination, inspection and contract delivery. For both U.S. and non-U.S. owned policies, there should be enough time spent in the U.S. to facilitate information gathering and adequate time to complete the underwriting and policy delivery process. The producer must provide Voya evidence and documentation of the delivery of the policy to the policy owner in the U.S.

Keeping Compliant


Policy Activation

Policy Administration

1AML/OFAC Voya’s usual anti-money laundering and OFAC procedures will be followed. Voya’s administrative system will recognize whether an agent has completed his/her AML training. If the agent has not completed the AML training an audit message will alert the case manager and the case manager will follow up with the agent until AML is complete. The administrative system will not allow a policy to be issued unless this requirement is received.

2Premium PaymentAll premium payments must be paid in U.S. currency from a bank or branch of a bank located in and subject to regulation in the U.S. Payments will be subject to standard compliance monitoring for money laundering.

3 Delivery of the Life Insurance Policy All Voya Life Companies’ policies will be mailed to the GA/Agent once issued. All policies must be delivered to the policy owner in person in the United States by the GA/Agent in the state where the policy is issued. The Policy Delivery Receipt (form #110474) must be received with signatures for all HNWFN non-U.S. owned polices before the policy will be activated. The producer should collect and retain evidence and documentation of the policy owner’s presence in the United States at the time of delivery. Use of a limited Power of Attorney may be available for policy delivery. If used, neither the agent, employee of the agency nor anyone else associated with the sale or solicitation of the policy may act as Attorney in Fact.


In-force Policy Administration

1 Solicitation and Servicing All policy solicitation and servicing must take place in the United States. Each customer will receive a disclosure covering the requirements and will sign an agreement confirming compliance and acknowledging that servicing will occur only in the U.S.

2 U.S. Address For U.S. and non-U.S. policy owners, the policy owner must provide a U.S. billing address acceptable to Voya that will be used for all policy communications. We require a U.S. address as the “billing address” in the ownership portion of the application. The policy owner may not use the address of the agent, agency or anyone else associated with the sale or solicitation of the policy as the billing address.

3 Policy Owner Internet and Call Center AccessCurrently, a policy owner uses their Social Security Number (SSN) to access policy information through the Voya Service Center website or call center (1-877-886-5050).

Because a HNWFN policy owner’s SSN may not already be on Voya’s policy administration system, affected policy owners will need to call the Voya Service Center at 1-877-886-5050 and establish a four digit personal information number (PIN). Once the PIN is established, the policy owner will have both web and phone access to their account information.

Voya.com

155480 01/01/2016

Life insurance products are issued by ReliaStar Life Insurance Company (Minneapolis, MN), ReliaStar Life Insurance Company of New York (Woodbury, NY) and Security Life of Denver Insurance Company (Denver, CO). Within the state of New York, only ReliaStar Life Insurance Company of New York is admitted, and its products issued. All are members of the Voya® family of companies. All death benefit guarantees are based on the financial strength and claims paying ability of the issuing company, which is solely responsible for obligations under its own policies.

For U.S. producers only, for use only in the United States. Not for public use or distribution. ©2016 Voya Services Company. All rights reserved. CN0106-20865-0218

We understand that the HNWFN world is a complex market. We’re here to help.

Please contact your local sales team or underwriter with any questions.

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